Justia Texas Supreme Court Opinion Summaries

Plaintiff sued BNSF Railway Company, his employer, under the Federal Employers’ Liability Act and the Locomotive Inspection Act to recover damages for a latent occupational injury. After a jury trial, the trial court rendered judgment awarding Plaintiff $1.9 million in costs and damages. BNSF appealed, arguing that Plaintiff’s lawsuit was untimely. The court of appeals affirmed, concluding that because there was conflicting evidence in the record concerning when the injury occurred, the jury was entitled to weigh that evidence and reach its finding that Plaintiff’s lawsuit was timely filed. The Supreme Court reversed and rendered judgment that Plaintiff take nothing, holding that no evidence supported the jury’s finding that Plaintiff timely filed his lawsuit. View "BNSF Ry. Co. v. Phillips" on Justia Law

Plaintiff sued Hospital, alleging that she was injured when she slipped on water on the floor. Hospital filed a motion to dismiss, asserting that Plaintiff’s claim was a health care liability claim (HCLC), and Plaintiff failed to serve an expert report as required by the Texas Medical Liability Act. The trial court denied Hospital’s motion. The court of appeals reversed, concluding that because Plaintiff’s claim was based on an alleged departure from accepted standards of safety, it was an HCLC. The Supreme Court reversed, holding that no substantive nexus was shown to exist between the safety standards Plaintiff alleged Hospital violated the the provision of health care, and therefore, Plaintiff’s claim was not a health care liability claim. View "Galvan v. Memorial Hermann Hosp. Sys." on Justia Law

Plaintiff sued Defendant for breach of contract and for wrongfully discharging him in retaliation for filing a workers’ compensation claim in good faith. Plaintiff’s breach of contract claim related to Defendant’s failure to remit accrued vacation pay upon his termination. A jury found in Plaintiff’s favor. The trial court rendered judgment in favor of Plaintiff, awarding him past and future lost earnings, employee benefits, and other damages. Defendant appealed the portion of the judgment on the retaliation claim. The court of appeals affirmed. The Supreme Court reversed and rendered a take-nothing judgment in favor of Defendant on Plaintiff’s retaliation claim, holding that no evidence supported the jury’s verdict on that claim. View "Kingsaire, Inc. v. Melendez" on Justia Law

Plaintiffs filed suit against Defendant, alleging breach of contract and misappropriation of trade secrets. Concerned by Plaintiffs’ counsel’s (Counsel) exposure to certain documents as a result of Counsel working “closely” with Defendant’s former finance manager, Defendant moved to disqualify Counsel from representing Plaintiff. The special master denied the motion to disqualify. The trial court, however, ordered Counsel’s disqualification. The court of appeals subsequently denied Plaintiffs’ petition for mandamus relief. The Supreme Court conditionally granted mandamus relief, holding that the trial court improperly disqualified Counsel under In re American Home Products Corp., as the American Home Products screening requirement does not govern a fact witness with information about his former employer if his position with that employer existed independently of litigation and he did not primarily report to lawyers. Rather, to the extent that a fact witness discloses his past employer’s privileged and confidential information, the factors outlined in In re Meador should guide the trial court’s decision regarding disqualification. View "In re RSR Corp. and Quemetco Metals Ltd., Inc." on Justia Law

Lorene and Harley Walter owned a certificate of deposit account with Bank of America. The account was a survivorship account and a payable-on-death account. After Harley died and while Lorene was still alive, the Bank distributed the funds in the account to Dwight Eisenhauer and Jo Ann Day, the named beneficiaries on the account, in equal sums. The Bank violated its deposit agreement with the Walters in doing so because these payments were made before Harley’s death. Eisenhauer, using his power of attorney, deposited his check into an account in Lorene’s name, making himself beneficiary upon her death. After Lorene died, Eisenhauer, as the independent executor of Lorene’s estate, sued the Bank for breach of the deposit agreement. The jury found that the Bank had failed to comply with the agreement but that the estate suffered no damages. The trial court subsequently granted judgment for Eisenhauer notwithstanding the jury’s verdict and rendered judgment for the amount that had been distributed to Day, plus interest, costs, and attorney fees. The court of appeals affirmed. The Supreme Court reversed, holding that the trial court erred in granting judgment notwithstanding the verdict to Eisenhauer, as the evidence supported the jury’s finding that the estate suffered no damages. View "Bank of America, N.A. v. Eisenhauer" on Justia Law

Political parties may apply to the Secretary of State for state funds to reimburse expenses connected with administering primary elections. After Wendy Davis was certified as the Democratic nominee for State Senate District 10 in the primary election, Davis’s Republican opponent sued to remove Davis from the general election ballot. The challenge failed, and Davis prevailed in the general election. The state and county Democratic Party chairpersons subsequently applied for reimbursement of attorney’s fees related to defending the challenge to Davis’s candidacy. The Secretary of State declined to reimburse the legal expenses to the Democratic Party because the party incurred those expenses after the primary election and in connection with the general election. The district court upheld the Secretary’s decision. The Court of Appeals reversed, concluding that the legal expenses were plainly connected to the primary election because they were based on Davis’s alleged constitutional ineligibility to appear on the primary election ballot. The Supreme Court reversed, holding that the Secretary did not abuse his discretion in denying the requested reimbursement from the primary election fund, as the Secretary is not obligated to reimburse a political party for legal expenses incurred in defending its nominee’s right to appear on the general-election ballot. View "Cascos v. Tarrant County Democratic Party" on Justia Law

Plaintiff, a visitor at Hospital, fell when she slipped on a floor mat in the hospital lobby. Plaintiff sued Hospital on a premises liability theory. Hospital asserted that Plaintiff’s claim was a health care liability claim (HCLC) under the Texas Medical Liability Act, and therefore, the claim must be dismissed because Plaintiff did not serve an expert report as required by the Texas Medical Liability Act. The trial court denied Hospital’s motion to dismiss. The Court of Appeals reversed, concluding that the floor care of the hospital lobby had an indirect relationship to the provision of health care that was sufficient to satisfy the safety prong of the Act, and therefore, Plaintiff’s claim was an HCLC. The Supreme Court reversed and remanded for further proceedings, holding that the record did not reflect a substantive nexus between the safety standards Plaintiff claimed Hospital violated and Hospital’s provision of health care. View "Reddic v. E. Texas Med. Ctr. Reg’l Health Care Sys." on Justia Law

Kachina Pipeline Co., a pipeline operator, and Michael Lillis, a natural-gas producer, entered into a Gas Purchase Agreement. Kachina bought, transported, and resold Lillis’s gas according to the Agreement. Lillis later entered into a separate purchase agreement and constructed his own pipeline to one of Davis Gas Processing’s plants. Thereafter, Lillis sued Kachina, asserting that Kachina breached the Agreement by deducting the costs of compression that occurred after he delivered the gas to Kachina. Lillis also brought a fraud claim, asserting that Kachina represented it would release him from the Agreement. Kachina counterclaimed for breach of the Agreement and seeking declarations that it had the right to deduct compression charges under the Agreement. The trial court granted summary judgment for Kachina, declaring that the Agreement entitled Kachina to deduct the costs of compression from its payments to Lillis and that the Agreement gave Kachina the option to extend the arrangement for an additional five-year term. The court of appeals reversed, concluding that the agreement unambiguously allowed neither the disputed deductions nor a five-year extension. The Supreme Court affirmed, holding that the Agreement did not allow Kachine to deduct compression costs or support a five-year extension. View "Kachina Pipeline Co., Inc. v. Lillis" on Justia Law

Plaintiff, a spectator at a youth softball game was injured in a trip-and-fall accident while exiting a baseball complex in a City park. Plaintiff filed a premises-liability lawsuit against the City, alleging that the City violated its duty of ordinary care by creating an unreasonable risk of harm and failing to provide a safe walkway passage. The City filed a plea to the plea to the jurisdiction asserting that it retained its immunity from suit under the recreational use statute, which raises the liability standard required to trigger the Texas Tort Claims Act’s immunity waiver in premises-defect cases involving lands opened to the public for “recreation.” The trial court denied the plea. The court of appeals reversed, concluding that spectating at a sporting event constitutes recreation. The Supreme Court reversed, holding that spectating at a competitive-sporting event is not “recreation” under the recreational use statute. Remanded. View "Lawson v. City of Diboll" on Justia Law

After Ginger Weatherspoon was fired from her position as an assistant attorney general at the Office of the Attorney General (OAG), Weatherspoon sued the OAG under the Whistleblower Act. The OAG filed a plea to the jurisdiction, arguing that Weatherspoon’s allegations were not sufficient to invoke the Act and waive the state entity’s immunity from suit for retaliatory discharge. The trial court denied the OAG’s plea. The court of appeals affirmed. The Supreme Court granted the OAG’s petition for review, reversed the court of appeals’ judgment, and dismissed the case, holding that Weatherspoon could not show that her reports met the Act’s requirements, and therefore, the OAG remained immune from suit. View "Office of Attorney Gen. v. Weatherspoon" on Justia Law